Six takeaways from our latest vulnerability workshop

By Ombudsman Services | Jul 19, 2019

We recently hosted the third in a series of workshops for communications providers on the theme of vulnerability and how best to support vulnerable consumers.

More than 30 delegates from telecoms providers of varying sizes took part in practical sessions and heard from the following guest speakers:

  1. Cordelia Hay – research director, BritainThinks
  2. Emma Bantges – customer operation enhancement manager, Cabot Financial
  3. Steve Brogden – senior consumer vulnerability manager, British Gas
  4. Daniel Bowling – senior policy officer, Information Commissioner’s Office (ICO)

Here are six key takeaways from the day:

1. Sometimes people don’t know if they’re ‘vulnerable’

It’s clear that consumers, unsurprisingly, have difficulty recognising whether or not they should be classified as vulnerable. This confusion was reflected in data presented to attendees by Jonathan Lenton, communications ombudsman at Ombudsman Services. The data showed that while only 5% of people who bring a complaint about their provider to Ombudsman Services state that they require additional support, a much higher proportion display signs of vulnerability in what they tell us.

Cordelia from BritainThinks, presenting research that the organisation produced for the Competition and Markets Authority (CMA) last year, said a common question amongst consumers who were interviewed for the research was “How do I know if I’m vulnerable?”

2. Vulnerable consumers often want the same things as the rest of the population

BritainThinks found that vulnerable consumers often want the same things from their communications providers as the rest of the population. Things like good customer service, clear prices and bills and flexibility contracts / packages are important for all consumers. There is, however, a greater desire for certainty on pricing amongst financially vulnerable consumers who, by definition, are living on a very tight budget. Some vulnerable consumers interviewed by BritainThinks were reluctant to switch provider or package through fear of disruption to communications services that they depend on.

3. Vulnerability awareness should be a part of your company’s culture

This message was conveyed strongly by Emma from Cabot Financial. Emma emphasised the importance of ensuring that all front-line staff receive adequate and ongoing training on how to identify vulnerability – for example by knowing the key ‘trigger phrases’ to look out for – and offering additional support to customers in vulnerable circumstances.

4. There’s a difference between inability to pay and unwillingness to pay

On the topic of financial vulnerability, various speakers agreed that there is a need for providers to recognise the difference between customers who can’t pay and those who won’t pay. Making this distinction might not be easy, but a message that came out of the event was that providers need to have a detailed picture of a customer’s circumstances in order to make an informed assessment of any additional support they might require.

5. We all have a role to play in spotting vulnerability

Steve from British Gas gave a presentation on the Friends Against Scams initiative run by National Trading Standards (NTS). The scheme aims to protect and prevent vulnerable consumers from becoming victims of scams by empowering people across the country to look out for warning signs.

It aims to inspire action, highlight the scale of the problem, change the perceptions of why people fall for scams and make scams a community, regional and national topic.

Steve emphasised that companies in all sectors have a role to play in raising awareness of the issue and ensuring their customers are protected from fraudsters.

6. Data protection laws aren’t a barrier to addressing vulnerability

Daniel from the ICO was clear that GDPR and the Data Protection Act 2018 shouldn’t be seen by businesses as a roadblock to implementing effective policies and procedures on vulnerability. On the issue of identifying and recording the fact that a customer is in vulnerable circumstances, Daniel reminded attendees that consent is only one lawful basis for processing personal data and that others – chiefly legitimate interest – should be considered.

Get in touch

Our vulnerability workshops were launched in response to changes introduced by Ofcom on 1 October 2018, which placed a requirement on communications providers to have clear, effective policies and procedures in place for identifying vulnerable customers.

If you are interested in attending a future workshop, please email

Spaces are limited but we will always strive to accommodate attendees wherever possible.